Duane B. and Linda L. Erwin, et al. - Page 10

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            passages from the petition, and the attachments thereto, that we                               
            have quoted above.  See Abrams v. Commissioner, 82 T.C. 403                                    
            (1984); Rowlee v. Commissioner, 80 T.C. 1111 (1983); McCoy v.                                  
            Commissioner, 76 T.C. 1027 (1981), affd. 696 F.2d 1234 (9th Cir.                               
            1983).                                                                                         
                  The Court's Order dated June 30, 1995, provided petitioners                              
            with an opportunity to assign error and allege specific facts                                  
            concerning their liability for the taxable year in issue.                                      
            Unfortunately, petitioners failed to properly respond to the                                   
            Court's Order.  Rather, petitioner elected to continue to proceed                              
            with time-worn tax protester rhetoric.  See Abrams v.                                          
            Commissioner, supra; Rowlee v. Commissioner, supra; McCoy v.                                   
            Commissioner, supra; Karlin v. Commissioner, T.C. Memo. 1990-496.                              
                  We see no need to painstakingly address petitioners' basic                               
            argument.  The short answer to it is that petitioners are not                                  
            exempt from Federal income tax or from the imposition of                                       
            appropriate penalties and additions to tax.  See Abrams v.                                     
            Commissioner, supra at 406-407.  Moreover, as the Court of                                     
            Appeals for the Fifth Circuit has remarked: "We perceive no need                               
            to refute these arguments with somber reasoning and copious                                    
            citation of precedent; to do so might suggest that these                                       
            arguments have some colorable merit."  Crain v. Commissioner, 737                              
            F.2d 1417, 1417 (5th Cir. 1984).                                                               
                  Because the petition fails to state a claim upon which                                   
            relief can be granted, we will grant respondent's motion to                                    




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